## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

CASE NO.: 09-CV-80802-MARRA-,

JANE DOE NO. 8

Plaintiff, v.

JEFFREY EPSTEIN,

Defendant.

## DEFENDANT JEFFREY EPSTEIN'S UNOPPOSED MOTION FOR EXTENSION OF TIME IN WHICH SERVE RESPONSIVE PLEADING TO COMPLAINT

Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorneys, respectfully moves this Court for an extension of time in which to respond to Complaint dated May 28, 2009 [DEq]. Defendant seeks an extension until July 14, 2009, to file his response. As good cause in support of granting the motion, Defendant states:

- 1. On May 28, 2009 Plaintiff filed a Complaint [DE 1]. Defendant's response would be due on July 7, 2009.
- 2. There are several other cases filed with this Court in which Jeffrey Epstein is named a Defendant. In those cases, the undersigned has been preparing responses to Motions for Protective Order and handling other matters associated therewith.
- 3. The requested extension is fair and reasonable under the circumstances as it will provide time to allow the Defendant, EPSTEIN to fully and adequately respond.
- 4. As certified below, counsel for Defendant conferred with counsel for Plaintiff, and Plaintiff's counsel is in agreement with the requested extension.

Jane Doe No. 8 v. Epstein Page 2

WHEREFORE Defendant respectfully requests that this Court enter an Order granting an extension until July 14, 2009, to file a response to Plaintiff's Complaint.

## Local Rule 7.1 Statement

Counsel for the movant conferred by telephone and correspondence with counsel for the Plaintiff and Counfiel for Plaintiff is in agreement wil, requested extension until July 14, 2009 for Defendant to respond to Plaintiff's Corn

R e, . rt D. C 'tton, Esq. Attorney for Defendant

## Certificate of Service

I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day on all counsel of record identified on the following Service List in the manner specified by CM/ECF on this 7ih day of July, 2009:

Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. 18205 Biscayne Boulevard Suite 2218 Miami, FL 33160 305-931-2200 Fax: 305-931-0877 ahorowitz@hermanlaw.com Irivera@hermanlaw.com Counsel for Plaintiff Jane Doe #8

Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 jagesq@bellsouth.net Counsel for Defendant Jeffrey Epstein Jane Doe No. 8 v. Epstein Page 3

Respectfully submitted,

BURMAN, CRITTON, LUTHER & COLEMAN, LLP

515 N. Flagler Drive, Suite 400 West Palm Beach FL 33401 (561) 842-2

tton, Jr.

#224162

Michael J. Pike

Florida Bar #617296

Counsel for Defendant Jeffrey Epstein

rcrit@bciclaw.com

mpike@bciclaw.com